04 - Motion to Extend Time to Submit Counter affidavit PDF

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Republic of the Philippines Department of Justice CITY PROSECUTORS OFFICE Davao City

PEOPLE OF THE PHILIPPINES, Complainant,

I.S. NO. FOR:

-versusPARK CHANYEOL, Respondent. x-------------------------------------------------x

MOTION FOR EXTENSION OF TIME TO SUBMIT COUNTER-AFFIDAVIT The respondent PARK CHANYEOL, by the undersigned counsel, most respectfully avers, that: 1. Respondent engaged the services of undersigned counsel only on February 13, 2021; 2. Respondents on February 4, 2021, received a subpoena from the Prosecutor’s Office charging him of the above-stated offense and requiring him to submit his counteraffidavit and other supporting documents within (ten) 10 days from receipt thereof; 3. Today, February 14, 2021, appears to be the last day for the submission of respondent’s counter-affidavit and other supporting documents; 4. There is a need to further study the case and to gather relevant evidence to support the defenses of the Respondent, thus, this request for a period of ten (10) day extension within which to submit the respondent’s Counter-Affidavit and other supporting documents; 5. That the filing of this motion is done in good faith and not for purposes of delaying the proceedings of this case but for the reason above-stated.

PRAYER WHEREFORE, Respondent most respectfully prays of this Honorable City Prosecutor of Davao City that he be given an additional period of ten (10) days from today within which to submit his counter-affidavit and other documentary evidence. MOST RESPECTFULLY SUBMITTED. Other relief just and equitable are likewise prayed for. Davao City, Philippines, February 14, 2021.

ATTY. ALEXANDRIA B. RABANES Counsel for Respondent

NOTICE OF HEARING

THE CLERK OF COURT Office of the City Prosecutor Davao City

Greetings! Please submit the foregoing motion for the consideration of the Honorable City Prosecutor immediately upon receipt hereof without further oral argument.

ATTY. ALEXANDRIA B. RABANES

Copy furnished by registered mail: PARK CHANYEOL Respondent 143 EXO Street, Davao City

ATTY. ALEXANDRIA B. RABANES Counsel for the Respondent 222 EXO-L Building, Davao City...